I am commenting on behalf of the Commercial Boat Operators Association (CBOA) represents water freight carriage by barge on the UK’s inland and estuarial waterways and is accepted by the Government as the representative industry body.

CBOA is interested in this planning application only in as far as the transport of materials is concerned and has no view on the suitability of the proposal with regard to land use or any other such desirability of the scheme.  We note that the Calder and Hebble Navigation is proposed for removal of all material raised, which we strongly support and agree with.  Barge use for material carriage produces less CO2 than lorry transport, is less hazardous on local roads, eliminates highway wear and tear from the extra freight movement meaning lower long term highway maintenance costs, and lower exhaust emissions meaning less air pollution in the district.

We note that an objection comment has been submitted as follows:

“The transport solution for removing the material from site (proposed river barges), while preferable to road traffic does not appear to be practical given lack of suitable infrastructure in this location and canal/river wider network.”  We would respectfully respond to this point in that the Aire & Calder navigation and the Calder & Hebble Navigation (to Greenwood Lock, beyond Ravensthorpe) are classified as Commercial Waterways under the 1968 Transport Act ‘principally for the carriage of freight’ and are presently an under used resource for this.  The above navigations are in fact well connected to various other Commercial Waterways including the Humber and its ports, River Trent, River Ouse and Sheffield and South Yorkshire Navigation reaching the towns and cities of Kingston upon Hull, Goole, Castleford, Leeds, Selby, York and others.

With respect to the Supporting Statement we have the following comments:-

Section 1.11 – Use of electrically powered barges may be an excellent way of further reducing noise and improving the environmental credentials of this scheme.  The total use of the navigation for removal of material from site is to be applauded.  We note that the scheme has the support of the Canal and River Trust.

Section 3.3 – We note that adequate protection of walkers etc on the foot path is provided with a cover.

Section 3.5 – We note that provision has been made for the wharf to accommodate two barges, one waiting while the other is being loaded.

Section 6.2.8 – We note that the destination wharves for the material have been adequately determined.